RE100’s updated technical criteria, published in March 2025, introduce more structured guidance for companies procuring renewable electricity—particularly for companies using renewable electricity via the purchase and redemption of Energy Attribute Certificates (EACs), also known as RECs.
These updates don’t represent a radical shift, but they do reinforce the importance of credibility, traceability, and impact in claims of renewable electricity use. At Monsoon, where we support corporate buyers with their EAC strategy and procurement across Asia and globally, we’ve taken a close look at the updates to help our clients stay aligned.
1. EAC Cancellation Is Now Mandatory in Key Markets
“Renewable electricity procurement must include EAC cancellation in markets where EACs are in common use.” — Section 5.2, RE100 Technical Criteria (2025)
This is one of the most important updates in the 2025 criteria. RE100 now requires companies to formally redeem/ cancel EACs when making claims to renewable electricity in markets where EACs (such as I-RECs or TIGRs) are widely used.
What’s changed:
In previous versions, EAC cancellation was recommended but not strictly required in all common-use markets. Now, it’s a condition for credible reporting starting with the 2027 CDP disclosure cycle.
When EAC Cancellation Is Mandatory
EAC cancellation is required in these situations:
- Contracts with electricity suppliers, including:
- Project-specific green tariffs
- Retail green supply contracts
- Unbundled REC/EAC purchases
- Virtual Power Purchase Agreements (VPPAs)
- Passive procurement with default grid supply, if it’s backed by EACs
“In markets where EACs exist but are not in common use, EAC cancellation may still support a claim… though EAC cancellation is not required by RE100 (unless any are issued to the generation being claimed).” — Section Five: 2, RE100 Technical Criteria (2025)
Even in markets where EACs aren’t yet common, RE100 recommends their use as a best practice, anticipating broader future requirements.
When EAC Cancellation Is Not Mandatory
RE100 clearly defines three exceptions to the EAC cancellation requirement:
- Self-generation
- Physical PPAs with no grid transfer
- Default grid supply in markets with ≥95% renewable mix and no EAC system
When in Doubt: Use EACs
“RE100 companies should use EACs for their claims across all procurement types even in the markets where they are not shown to be in common use, as a matter of best practice and in anticipation of EACs being required… in the future.” — Section Five: 2.1, RE100 Technical Criteria (2025)
2. Virtual PPAs Are Confirmed as a Form of Unbundled EAC Procurement
“A financial power purchase agreement… is therefore a form of unbundled procurement.” — Section 2.2, RE100 Technical Criteria (2025)
Virtual power purchase agreements (VPPAs) are popular for long-term renewable electricity sourcing, especially where physical delivery is complex. The 2025 update clarifies that VPPAs deliver financial instruments and EACs – but not the physical electricity itself – which means they are classified as “unbundled” procurement.
Why this matters:
Unbundled procurement types face additional scrutiny under RE100, including market matching, vintage requirements, and now, the fifteen-year age limit (more below). Treating VPPAs as unbundled EACs helps clarify how they should be reported.
3. The 15-Year Limit is Now Enforced
“Renewable electricity procurement must observe a fifteen-year commissioning or re-powering date limit.” — Section 5.4.2, RE100 Technical Criteria (2025)
To encourage support for newer renewable projects, RE100 now requires that most EACs come from power plants commissioned or re-powered within the last 15 years. A grace threshold of 15% is allowed for older sources.
What’s changed:
Earlier versions introduced this concept, but the 2025 criteria clarify how it is applied, including what counts as “original off-take” and how to report commissioning dates.
What to do:
If your company purchases RECs or enters a VPPA, make sure the projects meet the commissioning year limit – or account for them carefully under the 15% threshold.
Monsoon delivers verified RECs from our exclusive network of eligible projects, ensuring full compliance with RE100’s 15-year commissioning rule.
4. Improved guidance around the sustainability assurance requirement for biomass and hydropower
RE100 counts renewable electricity from biomass and hydropower toward targets only if the buyer has assurance it was generated sustainably. While third-party certification is recommended, it is not mandatory. This flexibility is helpful in regions where independent verification is unavailable.
Fortunately, other forms of assurance are acceptable, which leaves it up to the buyer to determine what information or assurance they need. For example, they might accept assurance on the sustainability of the feedstock for biomass plants (e.g. agricultural residues only), or they might limit the size of the hydropower plants they buy RECs from (e.g. <30MWp), or require evidence of environmental and social compliance.
5. EACs as the Default Standard for Credible Claims
“Energy attribute certificates are recognized as the best method for tracking and establishing ownership of energy attributes.” — Appendix A, RE100 Technical Criteria (2025)
This foundational statement strengthens the role of EACs as the key instrument for renewable electricity claims. While contracts can still be used in some markets, the global standard is now clearly EAC-driven.
What this means for your company:
Using recognized, tracked, and cancelled certificates is the most accepted – and in many cases, required method to support your renewable electricity goals.
Going forward, companies are encouraged to use EACs not just for compliance – but as a best practice for demonstrating transparency and ownership. Monsoon makes this process simple and efficient through providing traceable, verified REC procurement and redemption.
Summary of Key Updates for REC Users
| Topic | Old Approach | 2025 Update |
| EAC Cancellation | Recommended | Required in common-use markets |
| Virtual PPAs | Some ambiguity | Clearly defined as unbundled procurement |
| Commissioning Date Limit of 15 years | Introduced (2022) | Enforced with 15% allowance (2025) |
| Role of EACs | Recognized among several tools | Now the primary tool for credible claims |
How Monsoon Can Help
As a leading provider of Renewable Energy Certificates, Monsoon helps clients:
- Source RECs from eligible, traceable, and RE100 compliant projects
- Ensure proper cancellation and documentation for RE100/CDP reporting
- Understand and navigate market systems and guidelines
- Provide REC Processing Services helping your company to manage RECs from your solar rooftop assets or for your VPPAs or corporate PPAs
We provide practical, transparent REC solutions that align with RE100’s latest expectations – without overcomplicating your procurement.
Final Thoughts
RE100’s 2025 update doesn’t change the game, but it does make the rules clearer. For companies using EACs, especially through VPPAs or unbundled purchases, this is a helpful moment to refine their strategy and plan ahead for compliance.
If you’re reviewing your renewable electricity claims or planning your next REC purchase, we’re here to help make sure it’s credible, eligible, and simple.
📩 Contact Monsoon to discuss your EAC strategy.
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